Diabetes Cost Measure Misattributed to Ophthalmologists

Date: October 13, 2023

The American Society of Cataract and Refractive Surgery (ASCRS), the American Society of Retina Specialists (ASRS) and the American Academy of Ophthalmology (AAO), met recently with CMS to discuss issues with ophthalmologists inappropriately having the Diabetes Cost Measure attributed to those participating in MIPS if they reported at the group level. The meeting was in response to a June 28 joint ophthalmology letter pointing out that CMS’ implementation of the diabetes cost measure is not correctly attributing the costs to the physicians and providers the TEP workgroup intended, noting that the measure should be attributed to the physician taking care of the patient’s diabetes and not ocular complications.

The societies state that, for the 2022 reporting period CMS will review its statutory authority to make a change retroactively. CMS had already indicated they would make the appropriate change for the 2023 performance period. 

In addition, CMS staff plan to take another look at the targeted reviews that have been submitted related to this particular cost measure, including the ones that already have been adjudicated. Physicians should continue submitting targeted review requests if they believe they have been inappropriately attributed to this measure. Also, CMS urges anyone who filed for a targeted review and was denied filing for a reconsideration. CMS has the information for the reconsiderations already submitted, and any clinicians affected need to have their paperwork submitted for CMS to consider.

You are strongly advised to view your 2022 MIPS Performance Feedback as soon as possible. Physicians can view their 2022 MIPS Performance Feedback information on the Quality Payment Program (QPP) website using their HCQIS Access Role and Profile (HARP) credentials.

For more information, please refer to the 2022 Targeted Review User Guide (PDF). If you have questions about whether your circumstances warrant a targeted review, please contact the Quality Payment Program by phone at 866-288-8292 (TRS: 711) or by email at QPP@cms.hhs.gov.

As always, we are available and happy to assist you with issues related to this topic as well as on many other issues related to eye care coding and reimbursement.  Stay safe.

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